Nebulizer Cleaning—Final State Survey Worksheets Released

After almost two years, the Centers for Medicare and Medicaid Services released the final version of State Surveyor Worksheets that were part of a Pilot Safety Initiative regarding Hospital Conditions of Participation related to infection control.

Of interest to respiratory therapists was the guideline surveyors were using as part of the Respiratory Therapy/Ventilator worksheets which called for “rinsing nebulizers with sterile water “or tap water followed by isopropyl alcohol”. The AARC continues to receive inquiries from respiratory therapists about this issue.

AARC submitted written comments citing safety concerns and lack of any scientific evidence to support use of “isopropyl alcohol” as part of the cleaning process and engaged in a series of conference calls with the Centers for Medicare and Medicaid Services (CMS) and the Centers for Disease Prevention and Control (CDC) to resolve the issue. In the interim, CMS put a placeholder in their November 9, 2012 update until revised language could be crafted. AARC worked closely with CMS/CDC to draft language that reflects differences in newer technologies, noting that nebulizers are not alike.

The Respiratory Therapy/Ventilator section can be found in 4.C of the Surveyor Worksheet. The nebulizer issue is item 4.C.7. The revised language regarding nebulizer cleaning reads as follows:

“Jet nebulizers are for single patient use and are cleaned as per hospital policy, rinsed with sterile water, and air-dried between treatments on the same patient.

Note: Mesh nebulizers, which remain in the ventilator circuit and are not cleaned or disinfected, are changed at an interval recommended by manufacturer’s instructions. Nebulizer/drug combination systems are cleaned and disinfected according to manufacturer’s instructions.

You will note in the yellow box below 4.C.7 that nebulizer cleaning is listed as a “no citation” item; for information only. The memo to State Survey Agencies is still being drafted by CMS on these latest guidelines, but given past directions to the Agencies, this means that hospitals will not be issued citations at either the standard- or condition-level on the Form CMS 2567, Statement of Deficiencies and Plan of Correction, unless an Immediate Jeopardy situation is identified.

This is good news for hospital respiratory departments that have been long-awaiting news on revised guidelines.